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Money Market Mutual Funds as Substitutes for Federally Insured Bank Deposits

Jonathan R. Macey, Sam Harris Professor of Corporate Law, Corporate Finance, and Securities Law at Yale University, has published a paper discussing the role money market mutual funds play as alternatives to traditional bank accounts.  The paper also takes a critical look at the proposed reforms to money market funds, and how these reforms, if adopted, could spell the end of the money market fund industry, to the detriment of consumers and the economy.  According to Masey:

Missing from the debate so far has been an acknowledgment of the enormous benefits that money market funds have provided over the last 40 years, both to investors and to the financial system as a whole. For both individual and institutional investors, money market mutual funds provide a commercially attractive alternative to bank deposits. Money market funds offer greater investment diversification, are less susceptible to collapse than banks and offer investors greater disclosure on the nature of their investments and the underlying assets than traditional bank deposits. For the financial system generally, money market mutual funds reduce pressure on the FDIC, reduce systemic risk and provide essential liquidity to capital markets because of the funds' investments in commercial paper, municipal securities and repurchase agreements.

Macey also lays out some of the distinctive benefits of the money market industry in its current form:

Money market funds reduce pressure on the FDIC: Banks suffer from a fundamental mismatch between their liabilities (which are deposits that can be withdrawn at any time) and their assets (which normally are in the form of much longer-term and illiquid commitments such as mortgages or commercial loans). Because of this mismatch, banks are susceptible to runs in the absence of deposit insurance. The FDIC has served as a back stop to protect depositors and, thus, has decreased the propensity for runs on banks. Still, the less pressure that is placed on the FDIC's limited resources the better, particularly in light of the alarming rate at which banks continue to fail. Money market funds provide an alternative to bank deposits without the need for FDIC insurance. The $2.9 trillion that investors have placed in money market mutual funds would likely be deposited at banks if money market mutual funds did not exist. A stable $1.00 NAV and features such as check writing and no limits on the number of withdrawals make money market funds an attractive investment for short-term cash management. At the same time, money market funds do not suffer from the same structural mismatch between their assets and liabilities because of the liquidity and maturity requirements of Rule 2a-7.

Money market funds reduce systemic regulatory risk: Having all short-term savings subject to one regulatory regime creates systemic risk. The different regulation of banks and money market funds serves as an important method to diversify the regulatory risks involved in protecting short-term savings. Some have called for money market funds to be regulated like banks, citing functional similarities such as check-writing services. Doing so would be a mistake. Imposing the bank regulatory scheme on money market funds would increase, rather than decrease, systemic risk. Homogenous regulatory practices create the possibility that the oversight practices miss the next potential financial crisis.

Money market funds provide valuable liquidity by investing in commercial paper, municipal securities and repurchase agreements: Money market funds are significant participants in the commercial paper, municipal securities and repurchase agreement (or repo) markets. Money market funds hold almost 40% of all outstanding commercial paper, which is now the primary source for short-term funding for corporations, who issue commercial paper as a lower-cost alternative to short-term bank loans. The repo market is an important means by which the Federal Reserve conducts monetary policy and provides daily liquidity to global financial institutions.

Given these benefits to investors and the economy, Macey argues that, though the money market industry could use some reforms, "improvements should come within the context of Rule 2a-7, should not alter the basic structure of the funds, and should not seek to impose arbitrarily a regulatory regime designed for a fundamentally different type of entity."  

The full text of Macey's paper is available at: